Dams · DRP News Bulletin

DRP News Bulletin 25 September 2017 (Three Incidents of Canals & Dam Breach In Two Days, Who Is Responsible?)

This week there have been three incidents of canals and dam breach in three States raising concern over quality of construction of dams and canals in India. 

All these incidents are a result of negligence exercised by concerned departments. These incidents also proves that the quality of construction of dams and canals in India is not as par standard. 

It is surprising that no government official or private contractor has been held responsible for these avoidable incidents. To avoid recurrence of such incidents, governments of these states bring the involved officials and persons to justice. It also strictly monitor the quality of construction to avoid wastage of public money. The safety of the public is also uncompromising and hence should not rush through the irrigation projects without proper consultation care. 

Continue reading “DRP News Bulletin 25 September 2017 (Three Incidents of Canals & Dam Breach In Two Days, Who Is Responsible?)”

Dams · DRP News Bulletin

DRP News Bulletin 18 September 2017 (Why Madhaya Pradesh Depleted Its Meagre Water Storage To Fill up SSP Dam For Sept 17?)

As per the Daily Status Reports of Narmada Control Authority[iv], inflow into SSP Dam suddenly jumped from 495 cumecs (Cubic Meters per second) on Sept 12, to 2518 cumecs on Sept 13, 2383 cumecs on Sept 14 and 2210 cumecs on Sept 15, 2384 cumecs on Sept 16, in anticipation of the birthday, so that when Narendrabhai visits the dam site to formally declare the project complete, the reservoir is seen to have substantial water. Expectedly, SSP water level rose from 126.19 m to 128.5 m by 8 am on Sept 15. How was this made possible?

Madhya Pradesh depletes its water storage so that SSP looks full on Sept 17? The increased inflow into SSP was made possible only by increased outflow from upstream Madhya Pradesh dams like Indira Sagar Project (ISP) on Narmada. ISP, incidentally is India’s largest reservoir in terms of storage capacity.

So the ISP storage level which was already very low (about 33%) on Sept 11 with monsoon almost coming to close, was depleted by further 450 MCM (Million Cubic Meters) from Sept 11 to Sept 16 (date for which latest information is available), while SSP water level rose by 750 MCM during the same period. All this, so that water level at SSP could look more respectable on Sept 17. Its not known why Madhya Pradesh is ready to lose water from its low storage levels (in fact, the water level at Omkareshwar Project on Narmada is below Minimum Draw Down level throughout this period).

Will Madhya Pradesh Chief Minister and MP Govt be held accountable for this by the media, judiciary and the people?

Continue reading “DRP News Bulletin 18 September 2017 (Why Madhaya Pradesh Depleted Its Meagre Water Storage To Fill up SSP Dam For Sept 17?)”

Dams · DRP News Bulletin

DRP News Bulletin 27 March 2017 (DON’T WE NEED TO LEARN TO TRULY CELEBRATE OUR RIVERS?)

This is about the proposed Brahmaputra Festival being planned by the Assam Govt from March 31 to April 4, 2017. The five-day festival will witness significant participation from China. Various other countries such as Vietnam and Singapore are also reported as attending the program. It is scheduled to be inaugurated by President Pranab Mukherjee.  

It is true that the word business appears four times on the opening page of this festival website, but the word flood, erosion and people do not appear even once. This is relevant since for very large sections of people of Assam, the river also means floods, erosion, displacement and disaster on regular basis and not just “lifeline of Assam” or “life-giving prosperity and countless blessings”.  

The festival website also errs in many ways, including when it claims “India’s only male river”, since there are several male rivers, including Damodar, Ajoy, Pagla, Gadadhar, among others. It is true that even the word Nemami is copied from the Nemami Gange, but that should not be such a big issue?

It is true that people also suffer when river dries up or is polluted or is encroached or unsustainably mined, and none of these issues are highlighted by the festival website. It is true that the the Assam also means all the communities, including the bodos and mishing and many others, not just Guwahati or Dibrugarh or Majuli. The festival organisers may argue that we are taking the festival to all 21 districts, but it is important to recognised all communities of Assam.

This is in addition to the fact that Brahmaputra includes all the states of North East India, and more. The Brahmaputra, 2,900 km long, is an international river with 918 km of it flowing in India, 1625 km in China and 337 km in Bangladesh.

It is true that the festival is more about attracting tourists, business and transport along the river. And so it is not even giving a comprehensive picture of the rivers of Brahmaputra basin in Assam, nor is there attempt to do anything to improve the state of the rivers. Similarly, the destruction of the rivers of Guwahati and Assam needs to be halted and reversed, and may be this occasion can be used to push that advocacy?

Continue reading “DRP News Bulletin 27 March 2017 (DON’T WE NEED TO LEARN TO TRULY CELEBRATE OUR RIVERS?)”

Dams · DRP News Bulletin

DRP News Bulletin 23 Jan. 2017 (Unjustified Ken-Betwa Link Costs: Bundelkhand To Gain Nothing, Panna To Lose Its Tigers)

SANDRP Blog Little for Bundelkhand, lot for contractors in Ken Betwa river-link The official executive summary of the Detailed Project Report of KBLRP on NWDA website says: “The main objective of the Ken-Betwa link project is to make available water to water deficit areas of upper Betwa basin through substitution from the surplus waters of Ken basin.” Upper Betwa basin (Raisen and Vidisha districts of MP) is not in Bundelkhand. So KBLRP is essentially facilitating export of water from drought prone Bundelkhand to area outside Bundelkhand, which, in fact is well endowed with over 900 mm of average annual rainfall.

The DPR further says, a third o the surplus water will be utilized for “enroute irrigation of 0.60 lakh ha. in the districts of Tikamgarh and Chhatarpur of MP and Mahoba & Jhansi of U.P.” The claim in the minutes of Expert Appraisal Committee meeting of Dec 30, 2016 that “It is proposed to provide irrigation facility in 6,35,661 ha of area in Panna, Chhatarpur, Tikamgarh Districts of Madhya Pradesh and Banda, Mahoba and Jhansi Districts in Uttar Pradesh” needs to be put in context here. Firstly, this claim is far in excess of what the presumed surplus water can irrigate.

Continue reading “DRP News Bulletin 23 Jan. 2017 (Unjustified Ken-Betwa Link Costs: Bundelkhand To Gain Nothing, Panna To Lose Its Tigers)”

Dams · DRP News Bulletin

DRP News Bulletin 09 Jan. 2017 (India Continues to Witness Decline in Groundwater: Govt Report)

Ground water recharge plan is a non-starter Though the latest report, covering assessment of ground level situation as on March, 2013, is still being compiled, sources in the Central Ground Water Board (CGWB) hinted at further increase in the number of `dark’ (over-exploited) units. Decline in ground water level due to over exploitation of available resources had prompted the Centre in 2013 to come out with a master plan for artificial recharge of ground water, specifying how different states would go about it on priority. But majority of the states have, so far, not implemented the master plan. Only six states -MP, Gujarat, W-Bengal, UP, Chhattisgarh and Karnataka have taken follow-up actions despite the fact that the number of `dark’ units increased from 802 in March, 2009 to 1,071 in March, 2011. This not only says what the title mentions, but also shows how slow our official agencies are in even coming up with groundwater data, the latest data is for March 2011! 

Continue reading “DRP News Bulletin 09 Jan. 2017 (India Continues to Witness Decline in Groundwater: Govt Report)”

DRP News Bulletin

DRP News Bulletin 19 Dec 2016 (Veteran environmentalist and water conservationist Anupam Mishra passed away)

Above: Anupam Mishra ji at the inaugural session of India Rivers Week 2016

Very sad to say that Anupam Mishra ji is no more. He breathed his last at AIIMS, Delhi at 5.27 am today (Dec 19 2016).

A person with such clarity of thought on water and river issues of India, such effective and simple way of communication, so affectionate and yet so humble will be difficult to find. As Ravi Chopra says, he was truely ANUPAM.

He was chairman of organising committee of India Rivers Week 2016 and also member of of Bhagirath Prayas Samman Jury since inception in 2014 and chairman since 2015. In spite of his poor health and weak body, he came to our organising committee meeting several times, last one in Sept 2016 and also came to the inaugural session of IRW 2016 on Nov 28, 2016 and spoke with characteristic clarity and simplicity and yet effectiveness. He was completely exhausted and pain at the end of it, but that he came in spite of that showed his dedication to the cause.

Personally he was most affectionate and encouraging to me, for so many years. God only knows how can one think of losing someone like that.

Himanshu Thakkar Continue reading “DRP News Bulletin 19 Dec 2016 (Veteran environmentalist and water conservationist Anupam Mishra passed away)”

Dams · DRP News Bulletin

DRP News Bulletin 11 Oct 2016 (Is there any justification for DESTRUCTION of Panna Tiger Reserve?)

Is there any justification for DESTRUCTION of Panna Tiger Reserve? Can we save our Natural Heritage like the Panna Tiger Reserve (PTR) from being destroyed in the name of baseless, questionable, non transparent, undemocratic and manipulated projects like Ken Betwa inter linking ? It will facilitate export of water from Bundelkhand to OUTSIDE Bundelkhand. Whatever little benefits are claimed, some of them are already available and much more can become available at much lower costs, faster and without destroying the Forests and Tiger Reserve. The project will actually lead to destruction of Ken catchment and hence the Ken River itself. Watch this FASCINATING, AWESOME story of tigers of PTR. This BBC film where Raghu Chandawat is the story teller and Pradip Kishen is lending his voice, tells the story of Tigers of Panna till 2003, it seems. Please watch and let us all try to save it from destruction that is now writ large in terms of Ken-Betwa Link Project (KBLP). One more short film by wildlife biologist Koustubh Sharma illustrates how the Daudhan Dam under KBLP will submerge and destroy the PTR.

Meanwhile, a new analysis of rainfall data reveals that monsoon shortages are growing in river basins with surplus water and falling in those with scarcities, raising questions about India’s Rs 11 lakh crore plan to transfer water from “surplus” to “deficit” basins. According to Himanshu Thakkar of SANDRP river basin interlinking should be considered only after exhausting the local potential for harvesting rain, recharging groundwater, watershed development, introducing better cropping patterns (non water-intensive crops) and methods (such as rice intensification), improving the soil moisture-holding capacity and saving and storing water. Raising alarm over significant increase in ground water use, increasing reliance and fast declining ground water table, he warns that inter-basin links would actually reduce groundwater recharge because forests would be destroyed, the river flow stopped and the local systems neglected.

Continue reading “DRP News Bulletin 11 Oct 2016 (Is there any justification for DESTRUCTION of Panna Tiger Reserve?)”

Dams · Indus

So who will suffer in the Indus water imbroglio?

Diplomatic and military strategies, by definition, are not decided through public debates. So the jingoism around Indus treaty with Pakistan seems more like an attempt at sending threatening signals. But it will have multiple serious ramifications in any case, so it is worth deliberating about.

The 1960 Indus treaty has allocated rights of development on three eastern tributaries (Sutlej, Beas & Ravi) to India, and we have exhausted that entitlement almost fully. Attempts to use the occasional remaining flow will mean a huge impact in Indian Punjab, which is unlikely to resonate well with the people of Punjab.  The treaty gave Pakistan dominant right of development of the three western tributaries (Chenab, Jhelum and Indus), India has limitations about water use (both in terms of quantity and manner of use) in case of the western rivers. India has not yet exhausted the entitlement in this case.

Continue reading “So who will suffer in the Indus water imbroglio?”

Dams · DRP News Bulletin

DRP News Bulletin 03 Oct 2016 ( Role of Uttarakhand Hydro Projects in Kedarnath Disaster 2013)

Book Review:  Rage of the Rivers: Role of Uttarakhand hydro projects in Kedarnath disaster 2013 by Hridayesh Joshi Rage of the River reads not unlike a gripping thriller. Thing is, it is not fiction. It is a true ‘story’ of a cataclysmic event, exacerbated by greed, and twisted notions of development manifested in blasting fragile hills, tunneling rivers, denuding forests, and encouraging illegal encroachments and mindless construction and tourism infrastructure. This is an important chronicle of one of the worst disasters of our times. Joshi has thoroughly analysed the role of endless, ill-planned hydel projects, but inexplicably fails to take into account the wreckage wrought by unrestrained tourism. Joshi points a finger at the unethical practices of construction companies, contractors and operators of hydel dam projects, even in the face of this monumental disaster. The officials of the Vishnuprayag project refused to listen to the pleas of the villagers to open the dam gates and allow the excess water to flow safely from under the barrage. The advice was ignored, either in ignorance of the gravity of the situation, or with an eye on the opportunity to generate more power. The rising waters broke the barrage flooding the valley and its villages.  

Continue reading “DRP News Bulletin 03 Oct 2016 ( Role of Uttarakhand Hydro Projects in Kedarnath Disaster 2013)”

Chenab · Cumulative Impact Assessment · Environment Impact Assessment · Expert Appraisal Committee · Himachal Pradesh · Hydropeaking · Hydropower · Ministry of Environment and Forests

Sach Khas Hydro project in Chenab Basin: Another example of WAPCOS’s shoddy EIA

Even after multiple appeals by various experts, organizations and local people, Expert Appraisal Committee (EAC) set up by Ministry of Environment & Forest (MoEF) has once again chosen to ignore alarms of changing climate such as disaster of Uttarakhand in 2013 and has continued to consider Hydro Power Projects on Chenab Basin for Environmental Clearance (EC) before the Cumulative Impact Assessment of Chenab Basin has been accepted by MoEF. While on one hand the State Government of Himachal Pradesh has promptly appointed a committee headed by Chief Secretary to supervise and monitor all the progress and to “sort out” problems of getting various clearances “without delay in single window system”[i], on the other hand overall transparency of the Environmental Clearance Process has been steadily decreasing.

Sach Khas HEP (260 + 7 MW) (located in Chamba District of Himachal Pradesh) was considered by EAC in its 76th meeting held on August 11, 2014. Even though the project was considered for EC, no documents were uploaded on the website. Website does not even list the project under “Awaiting EC” category. This is in clear violation with MoEF norms, basic norms of transparency and Central Information Commission (CIC) orders. There are no fixed guidelines for documents to the uploaded, the time by when they should be uploaded and rules that project cannot be considered if the documents are not uploaded.

SANDRP recently sent a detailed submission to EAC pointing out several irregularities of the project. The comments were based on reading of the Environmental Impact Assessment (EIA) report available on the HP Pollution Control Board Website (which cannot be substitute for putting up the documents on EAC website). Environmental Management Plan (EMP) of the project is not accessible at all! Non availability of EMP on the HP Pollution Control Board website too is a violation of EIA notification 2006.

The EIA report which is prepared by WAPCOS is another example of a poorly conducted EIA with generic impact prediction and no detailed assessment or quantification of the impacts. Moreover since EMP is not available in the public domain, there is no way to assess how effectively the impacts have been translated into mitigation measures. Violations of Terms of Reference (TOR) issued by EAC at the time of scoping clearance is a serious concern.

Project Profile

Sach Khas HEP is a Dam-toe powerhouse scheme. The project has a Concrete Dam & Spillway with Gross storage of 25.24 MCM, Live Storage of 8.69 MCM and Reservoir Stretch at FRL of 8.2 km (approx.) Three intakes each leading to 5.8m diameter penstocks are planned to be located on three of the right bank non-overflow blocks. Three penstocks offtaking from the intakes are proposed to direct the flows to an underground powerhouse on the right bank of the Chenab river housing 3 units of 86.67 MW turbines with a total installed capacity of 260 MW. The project also proposes to construct 2 units of 7 MW each to be installed to utilize the mandatory environmental releases. The EIA mentions (p 2.19) that the HP government has allocated 3.5 MW Hydropower project on Chhou Nala in the project area to the project authority, so this is integral part of the project.

Sach Khas Dam Site

Sach Khas Hydro Electric Project was considered before completion of Cumulative Impact Assessment of Chenab Basin

Chenab basin may have one of the highest concentrations of hydropower projects among all basins in India[i]. The basin has over 60 HEPs under various stages of planning, construction and commissioning in states of Himachal Pradesh (HP) and Jammu and Kashmir (J&K). 49 of these projects are planned or under construction in Chenab in HP and of which 28 projects of combined generation capacity of 5,800 MW are at an advanced stage of obtaining (Environment Ministry) clearances[ii]. MoEF sanctioned TORs for Cumulative Impact Assessment (CIA) of the HEPs on Chenab in HP in February 2012 however the project specific ECs were delinked from the CIAs[iii].

MoEFs Office Memorandum dated May 28 2013 states, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.”

We had pointed out in our submission against Kiru & Kwar projects in Jammu & Kashmir that CIA of all the proposed, under construction and operational projects and carrying capacity assessment (CCA) of the Chenab River basin to see if it can support the massive number of HEPs in safe and sustainable way is one of the first steps before considering clearances to HEPs in this region. Looking at the fragility of the Himalayan ecosystem, considering any hydropower project in the basin without these studies will be an invitation to disaster[iv]. This fact has been repeatedly highlighted by multiple organizations and experts including SANDRP.

Sach Khas EIA Study: Gross violation of TOR

The EIA violates several stipulations of TOR issued on Feb 22, 2013, which also included the stipulations of EAC in Sept 2012 and Nov 2012 meetings where the project TOR was considered and also Annexure attached with the TOR. This has severely affected the overall quality of the EIA report.

About assessing the impacts of the project on wild life the TOR said: “Reaching conclusion about the absence of such (Rare, Endangered & Threatened) species in the study area, based on such (conventional sampling) methodology is misleading” as such “species are usually secretive in behavior”, “species specific methodologies should be adopted to ascertain their presence in the study area”, “If the need be, modern methods like camera trapping can be resorted to”. None of this is shown to be done in any credible way in EIA.

TOR also recommends intense study of available fish species in the river particularly during summer (lean) months with help of experimental fishing with the help of different types of cast and grill nets. There is no evidence in EIA of any such intensive efforts detailed here. In fact the field survey in summer moths was done in May June 2010, years before the EAC stipulation.

TOR (EAC minutes of Sept 2012) state “Chenab river in this stretch has good fish species diversity & their sustenance has to be studied by a reputed institute.” This is entirely missing. TOR (EAC minutes of Sept 2012) states “During the day, the adequacy of this discharge (12 cumecs) from aquatic biodiversity consideration needs to be substantiated”. This again is missing. TOR said 10 MW secondary station may be a more desirable option. This is not even assessed. TOR said Impacts of abrupt peaking need to be assessed. This is also not done. Site specific E-Flow studies and peaking studies stipulated by TOR are missing. TOR states that Public Hearing / consultations should be addressed & incorporated in the EIA-EMP. However there is no evidence of this in the report.

TOR also required following to be included in EIA, but many of them found to be missing: L section of ALL upstream, downstream projects; Project layout showing all components with A-3 scale of clarity and 1: 50000 scale; drainage pattern map of river upto project; critically degraded areas delineated; Demarcation of snowfed/ rainfed areas; different riverine habitats like rapids, pools, side pools, variations, etc;

Contradictions in basic project parameters

The EIA report provides contradictions in even in basic parameters of the project components: So section 2.1 on page 2.1 says, “The envisaged tail water level upstream of the Saichu Nala confluence is 2150 m.” This i s when the TWL is supposed to 2149 m as per diagram on next page from the EIA. Section 2.3 says: “River bed elevation at the proposed dam axis is 2145m.” At the same time, the tail water level is 2149 m. How can Tail water level of hydropower project be higher than the river bed level at the dam site? This means that the project is occupying the river elevation beyond what HPPCL has allocated to it. Page 23 of EIA says: “…the centerline of the machines in the powerhouse is proposed at 2138.00m…” So the Centre line o the power house is full 11 m BELOW the tail water level of 2149 m? How will the water from power house CLIMB 11 m to reach TWL level?

EIA report unacceptable on many fronts

Dam ht of 70 m was stated in TOR, however the report states it to be 74 from river bed. The submergence area, consequently has gone up from 70 ha at TOR stage to 82.16 ha, as mentioned in Table 2.2 of EIA. Total land requirement which was 102.48 ha as per TOR ha has now increased to 125.62 ha, with forest land requirement going up to 118.22 ha. This is a significant departure from TOR that should be requiring fresh scoping clearance. Part of the field study has been done for the project more than four years ago and rest too more than three years ago. There are not details as to exactly what was done in field study. EAC had noted in their meeting in Sept 2012, while considering fresh scoping clearance for the project, “EIA and EMP should be carried out afresh keeping in view the drastic changes in the features due to increase in installed capacity of the power house.” (Emphasis added.) The EIA report is thus unacceptable on multiple fronts.

No cognizance of Cumulative Impacts

CIA of the entire Chenab basin including HP and J&K is not being considered, which itself is violating MoEFs Office Memorandum dated May 28 2013. The OM states that all states were to initiate carrying capacity studies within three months from the date of the OM No. J-11013/I/2013-IA-I. Since this has not happened in case of Chanab basin in J&K, considering any more projects in the basin for Environmental clearance will be in violation of the MoEF OM.

On Cumulative Impact Assessment, the OM said, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.” The EIA of both the projects does not include the cumulative impacts.

The project is located between Purthi HEP upstream and Duggar HEP downstream. Elevation difference between TWL of Purthi (2220m) and FRL of Sach Khas (2219m) is barely 1 m. The horizontal distance between them is as less as 117m. This is clearly unacceptable and in violation of the minimalist EAC-MoEF norms.

Elevation difference between TWL of Sach Khas (2149m) and the FRL of Duggar (2105 m) is 44 m and the horizontal distance is 6 km. This is thus a cascade of three among many other projects in the basin.

Cascade of three projects

Purthi HEP Site

Dugar HEP Site

Even so the report does not even mention the other two projects. EIA study is project specific and no cumulative impacts are assessed along with the other two projects. The EIA does not provide a list of all the HEP projects taken up in the Chenab basin in HP state[i]. The MoEF sanctioned TORs for conducting Cumulative Impact Assessment (CIA) of Chenab In February 2012. EAC considering any further project in Chenab basin before completion of the CIA study of the basin by a credible agency (not WAPCOS) and finalised in a participatory way will be in violation of the MoEF order of May 2013.

EIA report completely misses out on the detailed analysis of cumulative impacts in terms of disaster potential of the area and how the project will increase that; impacts on flora, fauna, carrying capacity, livelihoods; cumulative downstream impact, cumulative impact of hydro peaking. impacts on springs and drainage pattern; impacts of forest diversion on environment, hydrology and society and implementation of the Forest Rights Act; changing silt flow pattern in different phases, impacts of mining, tunneling, blasting etc. Impact of reduction in adaptive capacity of the people and area to disasters in normal circumstance AND with climate change has not been assessed. Project makes no assessment of impact of climate change on the project even when over 60% of the catchment area of the project is snow-fed and glacier fed. Options assessment in terms of non dam options as required under EIA manual and National Water Policy are missing.

Generic impact prediction

Impact prediction is too generic with no detailed assessment, which is what EIA is supposed to do. Impacts have not been quantified at all. The EIA report merely states the likely impacts in 2 or 3 sentences. Several important impacts have gone missing. None of the serious impacts have been quantified. For an informed decision making and effective mitigation and EMP quantification of impacts is essentially a pre requisite. Following are some such incidences:

Impacts of blasting & tunneling: TOR for the impacts on “Socio-economic aspects” says, “Impacts of Blasting activity during project construction which generally destabilize the land mass and leads to landslides, damage to properties and drying up of natural springs and cause noise pollution will be studied.”(p.196 of EIA Report). The total area required for Underground Works is 2.44 Ha. The project proposes underground power house with an installed capacity of (260+7). There are three TRTs proposed of length 99.75m, 113.13m, and 132.35m. Even so the impacts of blasting for such huge construction are simply disregarded in the EIA report by stating that “The overall impact due to blasting operations will be restricted well below the surface and no major impacts are envisaged at the ground level.” (p.165). While assessing the impacts of blasting on wild life the report states that direct sighting of the animals has not been found in the study area and the possible reason could be habitation of few villages. No attempt has been made to assess impacts of blasting like damage to properties, drying up of springs etc. This is a clear violation of TOR.

Impacts of Peaking & diurnal flow fluctuation: In the lean season during peaking power generation the reservoir will be filled up to FRL. As stated in report, this will result in drying of river stretch downstream of dam site of Sach Khas hydroelectric project for a stretch of 6.0 km, i.e. upto tail end of reservoir of Dugar hydroelectric project. The drying of river stretch to fill the reservoir upto FRL for peaking power will last even upto 23.5 hours, after which there will continuous flow equivalent to rated discharge of 428.1 cumec for 0.5 to 2 hours. Such significant diurnal fluctuation with no free flowing river stretch will have serious impacts on river eco system. There is no assessment of these impacts. Instead the report projects this as a positive impact stating “In such a scenario, significant re-aeration from natural atmosphere takes place, which maintains Dissolved Oxygen in the water body.” This is absurd, not substantiated and unscientific.

International experts have clearly concluded that: “If it is peaking it is not ROR”[ii]. In this case the EIA says the project will be peaking and yet ROR project, which is clear contradiction in terms.

Impacts on wild life: EIA report lists 18 faunal species found in the study area. Out of them 8 species are Schedule I species and 8 Schedule II species. Even so while assessing the impacts of increased accessibility, Chapter 9.6.2 b(I) of the report mentions “Since significant wildlife population is not found in the region, adverse impacts of such interferences are likely to be marginal.” If the project has so many schedule I and II species, the impact of the project on them must be assessed in the EIA. Moreover, massive construction activities, the impacts of long reservoir with fluctuating levels on daily basis, high diurnal fluctuation and dry river stretch of 6km on wild life could be serious. But the report fails to attempt any assessment of the same.

Impacts on geophysical environment are missing: The project involves Underground Works of 2.44 Ha. This involves construction of underground powerhouse, three headrace tunnels and several other structures. This will have serious impacts on the geophysical environment of the region and may activate old and new landslides in the vicinity of the project. The report makes no detailed assessment of this. Generic comments like “Removal of trees on slopes and re-working of the slopes in the immediate vicinity of roads can encourage landslides, erosion gullies, etc.” (p.176) have been made throughout the report. Such generic statements can be found in every WAPCOS report. Such statements render the whole EIA exercise as a farce. Project specific, site specific impact assessment has to be done by the EIA. Considering that the project is situated between Purthi HEP upstream and Duggar HEP downstream, a detailed assessment of the geophysical environment and impact of all the project activities is necessary. Further since the EMP is not at all available in public domain, it is difficult to assess what measures are suggested and how effective measures to arrest possible landslides have been suggested.

Downstream view of Sach Khas

Right Bank Drift at Sach Khas

No assessment for Environmental Flow Releases

TOR states that the minimum environmental flow shall be 20% of the flow of four consecutive lean months of 90% dependable year, 30% of the average monsoon flow. The flow for remaining months shall be in between 20-30%, depending on the site specific requirements (p.192). Further the TOR specifically states that a site specific study shall be carried out by an expert organization (p.193).

The TOR also mandated, “A site specific study shall be carried out by an expert organisation.” However completely violating the TOR, the EIA report makes no attempt for the site specific study to establish environmental flows. Instead it proposes to construct 2 units of 7 MW each to be installed to utilize the mandatory environmental releases. This completely defeats the basic purpose of the environmental flow releases. Such flows will help neither the riverine biodiversity, nor fish migration nor provide upstream downstream connectivity.

Socio-economic profile of the study area and Rehabilitation & Resettlement Plan are missing

TOR specifies a detailed assessment of socio-economic profile within 10 km of the study area including demographic profile, economic structure, developmental profile, agricultural practices, ethnographic structure etc. It also specifies documentation sensitive habitats (in terms of historical, cultural, religious and economic importance) of dependence of the local people on minor forest produce and their cattle grazing rights in the forest land. As per the TOR the EIA report is required to list details of all the project affected families.

Report however excludes assessment of socio economic impact of the study area. The total land required for the project is 125.62 ha, of which about 118.22 ha is forest land and the balance land 7.4 ha is private land. There are cursory mentions of habitations in the study area. Chapter 8.7 ‘Economically Important plant species’ states that in study area the local people are dependent on the forest produce such as fruits, timber, fuel wood, dyes and fodder for their livelihood. However the EIA report does not even estimate the population displaced due to land acquisition and impact of the various components of the project on livelihood of the people. Further detailed study is then out of question. This is again gross violation of TOR.

Indus Water Treaty

Chenab basin is international basin as per the Indus Water Treaty. A recent order of the international court has debarred India from operating any projects below MDDL and has disallowed provision for facility to achieve drawdown below MDDL in any future project[i] (for details, see: https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/). The EIA described gate opening in this project for silt removal, which stands debarred by international court. The EIA thus is in violation of the verdict of international Court.

The EIA says (p. 21 bottom), “Five low level sluices with crest at 2167m of size 7.5m width and 12.3m height are proposed for flood passage. Drawdown flushing of the reservoir shall be carried out through these sluices for flushing out of the sediment entrapped in the reservoir. Detailed studies on sedimentation and reservoir flushing can be taken up at detailed planning stage.” The MDDL of the project is 2209.3 m as mentioned in the same para. This means the project envisages sediment flushing by drawdown to 2167 m (sluice crest level, the sluice bottom level wll be 12.3 m below that), about 42.3 m below the MDDL. This is clearly not allowed under PCA order cited above on Indus Treaty.

Impact of 3.5 MW Chhou Nala HEP to be constructed for the project not assessed

The EIA mentions (p 2.19) that the HP government has allocated 3.5 MW Hydropower project on Chhou Nala in the project area to the project authority, so this is integral part of the project. But the EIA does not contain any impacts of the SHP. The stream on which this is planned is extremely important for the people as drinking water schemes, irrigation Kuhls and gharats of Rai, Chhou and Thandal villages are located on this stream in the proposed project area. Thus the project will have huge impacts, but there is no assessment of these impacts. This is another glaring omission of EIA. It was shocking to read that the resident commissioner said at the public hearing that this question is not part of Environmental Public hearing, when it is very much part of it.

Public hearing report

At several places either no information is given or misleading information has been presented. For example the project representatives mis-informed the people at PH that 15-20% water will be released, when minimum water they need to release is above 20%. DFO said that soil will be spread over the muck disposal site for tree planting over it, but there is no provision of this in EIA-EMP. Many questions were provided with vague answers or no answers at all. No clear answer was given when asked if the muck dumping sites have been decided in consultation with the local people, implied answer is clearly that local people have NOT be consulted. When asked about agreements to ensure that the company implements EMP and Social Management Plan as required, there was no promise that such an agreement will be signed with the village gram sabhas. The affected people raised the issue of erosion impact of diversion tunnel, but no specific response was provided in response to this issue. When a resident of Chhou village raised the issue of vulnerability of the village to the landslides, no clear answer was given by the project developer. When the same person asked that our cremation ground is going under submergence, what is the company planning about it, the project developer replied that IF the cremation ground goes under submergence, we will think about this. This only shows that the project developer and EIA consultant have not even done an assessment of such basic aspects. The PH report accepts that close to 100 workers are already working without even basic sanitation facilities, this is clear violation of EIA notification further the EIA Agency fails to mention this.

EIA is full of cut and paste, generic statements, no actual assessments

Out of nine chapters of EIA, only the last chapter is about impacts assessments! So out of 170 pages of nine chapters, only 31 pages of chapter 9 is supposedly about impact assessment and there too mostly there is no real impact assessment, mostly only generic statements that can be included in any EIA. There are several unnecessary sections in the EIA like chapter 3 on “Construction Methodology” which is unnecessary in EIA. In most other sections too, the information is just cut and paste from DPR. By way of impact prediction, the EIA report is only listing them doing absolutely NO ASSESSMENT and no quantification of impacts is attempted. Further since the EMP is not available in the public domain, it is impossible to assess if the measures provided in the EMP are effective. Such EIA is definitely not acceptable.

No proper referencing The EIA does not provide references to the specific information, without this it is difficult to cross check which information is from which secondary sources and how credible it is and which information is from primary survey.

Conclusion

This is another most shoddy piece of EIA by WAPCOS.

Moreover, as we can see the EIA has not done several impact assessments, has violated large no of TORs on several counts, the EIA-EMP are not available on EAC website, the project parameters have undergone changes necessitating fresh scoping clearance as mentioned in TOR but that has not happened, baseline study is 3-4 years old, EAC stipulation of fresh EIA-EMP has been violated, Project is using larger riverine stretch than given by HP govt, there is no proper referencing, hydrology is weak, EMP is not available on HPPCB website in violation of EIA notification, among several other issues listed above. Every conceivable serious problem can be found in this EIA of WAPCOS.

It is full of generic statements that can be pasted in any EIA without any attempt at project specific impact assessment. SANDRP has been pointing to EAC and MoEF about such unacceptable EIA by WAPCOS for several years, but neither EAC, nor MoEF has taken any action in this regard. SANDRP has once again urged to EAC and MoEF to reject this EIA and recommend blacklisting of WAPCOS and to issue fresh scoping clearance for the project as mentioned in the TOR since the project parameters (dam height, submergence area, land requirement, etc) have gone through significant changes.

We sincerely hope the EAC will not only take serious cognition of these and not recommend clearance to the project, but also direct the project proponent and EIA consultant to implement other recommendations made above.

 Amruta Pradhan (amrutapradhan@gmail.com), Himanshu Thakkar (ht.sandrp@gmail.com)

[i] https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/

[ii] See for example https://sandrp.in/basin_maps/Hydro_%20Electric_Projects_in_Chenab_River_Basin.pdf

[iii] https://sandrp.wordpress.com/2014/07/01/if-its-peaking-its-not-an-ror-interview-with-dr-thomas-hardy-iahr-and-texas-state-university/

[iv] https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

[v] https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf

[vii] https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

[viii] Refer to SANDRP studies on Chenab

– https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

– https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf

– https://sandrp.wordpress.com/2014/05/06/massive-hydropower-capacity-being-developed-by-india-himalayas-cannot-take-this-onslought/

[ix] http://northgazette.com/news/2013/04/25/special-committee-to-monitor-hydro-projects-in-hp-cm/